Modified: July 7th 2021

Code of Conduct

Running a healthy business demands focus on sound code of conduct and ethical behavior in every aspect of the group companies’ processes and professional relationships. This “Code of Conduct” is Kahoot!’s main ethical framework and describes expectations, commitments and requirements for how we should act. Kahoot!’s Code of Conduct reflects our values, forms the foundation of our culture and is at the top level of Kahoot!’s governing document hierarchy. 

1 Introduction

1.1   Our purpose and values

Our purpose is to make learning awesome. The purpose sets the direction for our choices and priorities. It inspires innovation and drives change. Everything we do must be in line with our purpose.

Our values describe how we will deliver our purpose. They describe what we expect from each other, and from our contractors and business partners.. The values reflect the way we build and develop our product’s features, they impact design in the visual identity of the product, our brand and our team mentality. We consider our values as visual reminders of fundamental characteristics which shape and guide our everyday actions to drive excellence in business operation and priorities. The Values at Kahoot! are:

We are playful Play is the first language we learn. It’s how we discover the world and understand our place in it. When we make learning fun, we make it engaging for everyone.
We are curious Curiosity is part of human nature, and it lies at the heart of all great endeavors. It’s what turns learners into amazing leaders — and keeps those leaders learning.
We are inclusive We’re team players at Kahoot! and believe that no learner, or employee, should ever be left out. Kahoot! strives to ensure that everyone has the chance to succeed.

1.2   Who the Code applies to

The Code of Conduct applies to any person that is employed by, delivers work to or is otherwise engaged with the Kahoot! Group (the “Group”), including  board members and our business partners. 

To ensure that the Code is implemented, Kahoot! continuously conducts training of its employees on these matters, including during onboarding of new staff.

1.3   Compliance with laws and regulations

Employees shall comply with applicable laws and regulations. This applies to both external requirements and internal regulations, including law, regulations, policies, economic sanctions, instructions or governing documents in Kahoot! 

Kahoot! Is specifically preoccupied about following competition laws which apply to all business arrangements, whether they are in written, oral or any other form. Price fixing, bid rigging and other anti-competitive behaviors are prohibited.

Violations of applicable laws and regulations are not acceptable. Any violation or non-compliance shall be handled in accordance with Group procedure and may involve liability under labor, criminal and tort law.

Kahoot! should have a culture where there is openness and a low threshold for reporting illegal or reprehensible conduct. This means violations of legal rules, written ethical guidelines or ethical norms. Employees are entitled to submit anonymous notifications and can rest assured that the notifications will be treated in a proper and confidential manner. Our Whistleblowing Rules apply to these notifications, but they do not apply to matters relating to individual employees’ employment relationships, such as personnel conflicts or disputes to the employment agreement.

2 The Kahoot! Way

2.1   Corporate responsibility

Kahoot! takes corporate social responsibility and contributes to a sustainable, economic, social and environmental development in our industry. We believe engaging learning is the key to development and empowerment at school, at home and at work. Kahoot!’s focus as a company is to operate in a sustainable way, in alignment with the United Nations Sustainable Development Goals (“SDG”) and the impact on learning we’re aiming to make around the world.

Quality education: SDG 4 is to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all by 2030. SDG4 is key to Kahoot!’s mission and operations. We contribute to literacy, numeracy, overcoming language barriers, making learning more inclusive, and ensuring that learners acquire knowledge to promote sustainable development. Kahoot! supports quality education through our main platform, as well as its portfolio companies like DragonBox and Poio, award-winning math and learn-to-read apps, and the Drops apps, which make language learning natural with immersive visuals and play. Together, we are on a mission to empower children of any background to learn through play, and build the world’s largest sustainable learning community.

Making learning more inclusive: We at Kahoot! believe that learning should include everyone, and we work to eliminate barriers to education. Kahoot! is an easy-to-use tool for everyone, putting students front and center, with equal chances of becoming classroom heroes. In response to COVID-19 and the global shift to distance learning, Kahoot! offered free access to Premium features for all educators impacted by the pandemic, working to ensure that educators could continue to connect with and engage their students, whether in the classroom or at home. Inclusion is one of our core values, and it informs how we operate as an organization. We aim to be compliant with the Web Content Accessibility Guidelines (WCAG) version 2.0, to an AA conformance level. 

Please see Kahoot!’s Inclusion and Accessibility here

Kahoot! aims to foster partnerships with organizations and institutions that both share our vision for positive social impact and which have important content to offer the youth audience – our future game-changers. Our partnerships with such organizations as the United Nations, UNICEF, Common Sense Education, Amnesty International, Rebel Girls, the National Institutes of Health, the Marine Stewardship Council, and many more are examples of our strong shared commitment to this vision. In close collaboration with these partners on the important topics of human rights, children’s rights, bullying prevention, cyberbullying & online safety, diversity and inclusion, inspiring women in history, the dangers of drugs & alcohol use and sustainability, we’ve been able to engage millions of learners and their educators around the world. Our partnerships with such organizations as Tiimo and the Ad Council reflect our commitments to this belief and enable Kahoot! to offer meaningful and inspiring learning content that can open minds and break stereotypes associated with gender, ethnicity, religion and neurodiversity (e.g., ADHD and autism).

Reducing our environmental footprint: At Kahoot!’s headquarters in Oslo, Norway, we strive to keep our environmental footprint minimal by investing in an office with natural lighting and recycling, and using more clean energy. We focus on educating our employees on sustainability issues and engage them to participate in promoting sustainability. 

2.2   Open, honest and unambiguous communication

In order to make the right decisions and create the best learning and working environment, the internal communication in Kahoot! must be open, honest and unambiguous. The same applies to our external communication, which is important for people’s trust in Kahoot!

Both internal and external communication shall be timely and correct. Employees should give and receive feedback with the intention of making improvements and we speak up if something is not good.

Kahoot! values the creativity and free expression of our users and contributors. We are therefore committed to protect our users and provide a safe and engaging learning environment for all of our users. We take steps to protect our users from harmful and illegal content and reserve the right to remove content that breaches our policies and values. Content on the Kahoot platform shall comply with our Acceptable Use Policy and Editorial Guidelines, and we take measures to ensure the safety of our platform. These practices are detailed in our Safety Guide, where we also describe the tools we make available for users to increase safety in their own games, such as nickname generators. 

Kahoot! does not serve targeted ads on our users, and we do not sell or share user information with third parties for marketing purposes. We also do not allow sales activities such as advertising, marketing and other promotions on our platform unless this is expressly authorized by Kahoot.  

2.3   Privacy and security

All Kahoot! employees have a duty of confidentiality in relation to users, prospective users, other employees, Kahoot! and its Group’s activities. Thus, important stakeholders shall be able to rely on us to protect information and maintain confidentiality. The duty applies both externally and internally. The duty of confidentiality applies regardless of the circumstances under which we have received the information. Employees are bound by the duty of confidentiality even after the employment relationship with Kahoot! has ended.

Kahoot is dedicated to protecting the personal data that we process.  To honor our commitment to privacy, all employees shall be aware of and strictly comply with Kahoot!’s internal privacy policy, which sets out how personal data is collected, processed and used by Kahoot.  We ensure that data and information is kept safe by implementing a comprehensive information security program. 

2.4   Health, safety and environment (HSE)

Kahoot! Is committed to ensuring the safety of our employees and complying with all applicable health and safety laws and regulations and not engaging in any form of slavery. Kahoot! shall have a good working environment that promotes lifelong learning, physical, mental and social well-being. The corporate culture shall be open, safe and supportive. Every employee should strive to contribute to a good working environment and positive interaction with their colleagues. No personnel at Kahoot! shall work in hazardous situations. 

2.5   Discrimination and harassment

Inclusivity is one of our core values, and we believe our team’s diversity is a driver of success. Our global team includes members of over 30 nationalities. Kahoot!’s full team of top leaders, including the Executive Management, consists of, in total, 24 individuals of around 10 nationalities where 42% are women. By growing our team to include the voices of a diverse range of professionals, we are able to build a more dynamic and creative company culture at Kahoot!. As we collaborate and contribute our unique points of view, social and cultural awareness and language abilities, together we drive greater innovation and global growth. Members of the K!rew are protected in a safe work environment by the Norwegian Working Environment Act and the gender equality and discrimination act. We value a good work-life balance, invest in our employees and welcome feedback from all in our mission to make learning awesome.

Employment at Kahoot! is based on individual merit and qualifications directly related to professional competence.

Kahoot! greatly values and promotes diversity. We do not accept any form of discrimination based on factors such as gender identity or expression, age, pregnancy status, ethnicity, religion, mental or physical disability, sexual orientation or political conviction, nor does Kahoot! accept harassment, including unwanted sexual attention. This applies to all of Kahoot!’s employees’ interactions with users, other employees, suppliers, and others..

We treat people fairly and with respect and we shall not express opinions, make jokes or write messages that are offensive, derogatory or inappropriate.

2.6   Conflict of interests

A conflict of interest occurs when personal interests, participation in external activities or business interests can affect decisions that employees make on behalf of Kahoot! These could for example be due to close personal relationships, financial interests or positions of trust or similar roles or ownership interests. A conflict of interest can also arise between requirements and expectations from authorities, customer interests, Kahoot’s business goals and expectations from its owners. 

Kahoot! shall seek to avoid conflict of interests, but if they arise, we shall be open about them and solve them in an appropriate manner.

2.7   Inside information

Kahoot!s employees may get access to information about Kahoot! that is not publicly available, and that can affect the price of Kahoot!’s shares listed on Oslo Stock Exchange. Such information may be inside information, which shall be processed in a correct and legal manner. Employees shall not misuse inside information and shall follow Kahoot!s instructions for handling inside information.

2.8   Anti-corruption

Kahoot! has zero tolerance for all forms of corruption, including fraud, money laundering, bribery, and shall act in an open, transparent and accountable manner. Corruption implies that you give or receive an offer of an undue benefit related to your job, position of trust or the execution of a special task. A benefit could be money, discounts, coverage of costs, trips or participation in events. This implies that employees shall never accept or offer financial or other undue benefits. Employees must report offers of gifts or other benefits from customers or other parties in accordance with established rules and procedures.

Please see Kahoot!’s anti-corruption policy here (https://trust.kahoot.com/anti-corruption-policy/).

2.9   Substance abuse

Kahoot! shall be a drug free workplace. No one shall be under the influence of drugs or alcohol or other intoxicating substances while working for Kahoot! In social settings, and at events where it is appropriate and acceptable, alcohol can be served, though consumption in moderation is expected. 

Legal stimulants, such as prescribed medicines and tobacco are not regarded as intoxicating substances in this context.

2.10  Use of Kahoot!’s assets

Employees have access to Kahoot!’s assets to carry out their work tasks. This includes properties, equipment, corporate cards, software, systems and the like that is owned by the Group. Such assets shall be stored in a responsible manner and used in accordance with applicable guidelines. Kahoot! does not accept any form of misuse of the Group’s assets or funds.